Mandamus decisions / District of New Hampshire

Jasmine Patel Shardaben Patel v. Antony Blinken

District of New HampshireTalesha L. Saint-MarcDecided August 8, 2025No. 1:24-cv-00242

2,996 written decisions from 2,731 cases in the whole mandamus and agency-delay group, the group's newest decided November 12, 2026. Updated November 14, 2026 at 1:17 a.m. CT; the Passim connector counts the live collection, which can differ by the day's additions and retirements (which total to quote). Coverage: of the 1,617 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,406 (87%), 1,039 of them in this group, measured November 14, 2026. Some of what that search finds are not mandamus decisions. Tell us about a decision we're missing.

These are counts of past written decisions and dockets, not predictions of how any case will be decided. A distribution appears only when at least 5 decisions (or 5 dockets) are behind it; smaller groups are listed, not summarized. How it's counted.

What the decision decided

Each value cites the passage it was read from. Values read by a model were checked against that passage; values read by rule come from fixed text patterns. Read the decision before relying on either.

Agency	Department of State Read by a model Instead, Plaintiffs’ complaint focuses primarily on the conduct of consular officers at the Mumbai Consulate and policy decisions made outside of New Hampshire.
Form or filing	DS-260 (immigrant visa) Read by a model Plaintiffs’ DS-260 Immigrant Visa
What the suit asked for	Not recorded Read by a model
Kind of order	A magistrate judge's recommendation Read by a model REPORT AND RECOMMENDATION ON DEFENDANT’S MOTION TO DISMISS AND PLAINTIFFS’ MOTION TO CHANGE VENUE
Motion decided	Other motion to dismiss; Transfer Read by a model First, the Secretary contends that pursuant to Rule 12(b)(3), “venue does not exist in the District of New Hampshire,” and therefore the complaint should be dismissed or transferred pursuant to 28 U.S.C. § 1406(a).
Whose motion	Cross-motions Read by a model REPORT AND RECOMMENDATION ON DEFENDANT’S MOTION TO DISMISS AND PLAINTIFFS’ MOTION TO CHANGE VENUE
Disposition	Magistrate judge's recommendation A magistrate judge's report and recommendation. The district judge decides whether to adopt it, so it is not counted as either side's win. Read by a model REPORT AND RECOMMENDATION ON DEFENDANT’S MOTION TO DISMISS AND PLAINTIFFS’ MOTION TO CHANGE VENUE
Prevailing party	Neither side Read by a model REPORT AND RECOMMENDATION ON DEFENDANT’S MOTION TO DISMISS AND PLAINTIFFS’ MOTION TO CHANGE VENUE
The delay claim	Not decided here Read by a model However, because the court concludes that venue is improper in this District and that this matter should be transferred to the Northern District of Illinois, the court need not address the Secretary’s substantive arguments.
The other claims	Not decided here Read by a model However, because the court concludes that venue is improper in this District and that this matter should be transferred to the Northern District of Illinois, the court need not address the Secretary’s substantive arguments.
Months pending	Not stated Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model
Nationality	India Read by a model Shardaben is a citizen of India.
I-130 category	Family preference Read by a model In September 2004, Shardaben’s sister filed a Form I-130 (Petition for Alien Relative) with United States Citizenship and Immigration Services (“USCIS”) on Shardaben’s behalf.

How the case ended

Docket: No. 1:24-cv-00242
On the docket: This ruling (ECF 11)
Filed: August 20, 2024
Ended: September 9, 2025
Suit's filing to its end: 385 days
How it ended: Transferred
From the record: idb disp 0 (transferred to another district)

A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why. Other suits in this court.

The ruling's entry is the docket's one order or judgment entered the day of the decision. Both come from CourtListener's copy of the docket; check them there.

Supreme Court and First Circuit authority

District decisions bind no one. On the questions this decision raises, the Supreme Court decisions and the circuit's published decisions listed here bind this court; a circuit disposition marked nonprecedential was not published as precedent and is persuasive only. ImmCite status as read November 14, 2026. Check the current status before relying on one.

Trump v. Hawaii, 585 U.S. 667

Supreme Court, June 26, 2018. Mandel's facially-legitimate-and-bona-fide standard governs constitutional challenges to entry restrictions, and a citation to a valid statutory ground ordinarily satisfies it.

ImmCite: treatment available, history exists, not clearance
Department of State v. Muñoz, 602 U.S. 899

Supreme Court, June 21, 2024. A U.S. citizen has no fundamental liberty interest in a noncitizen spouse's admission, so marriage alone entitles the citizen neither to Mandel review of the consular refusal nor to an explanation beyond the statutory citation.

ImmCite: treatment available, history exists, not clearance
Kleindienst v. Mandel, 408 U.S. 753

Supreme Court, June 29, 1972. When a visa refusal burdens a U.S. citizen's own constitutional rights, courts ask only whether the Executive gave a facially legitimate and bona fide reason and do not look behind it.

ImmCite: treatment available, history exists, not clearance
Norton v. Southern Utah Wilderness Alliance, 542 U.S. 55

Supreme Court, June 14, 2004. Section 706(1) and mandamus reach only a discrete agency action that the agency is legally required to take, so a court cannot compel programmatic improvements or action the law leaves to agency discretion.

ImmCite: treatment available, history exists, not clearance
Adams v. Baker, 909 F.2d 643

First Circuit, July 26, 1990. A visa denial stands under Mandel where the government states a facially legitimate and bona fide reason, and the court will not weigh the evidence behind it.

ImmCite: caution, adverse or limiting treatment found. Clarified (jurisdictional description superseded by Muñoz), as recognized in Teles De Menezes v. Rubio, 156 F.4th 1 (2025).
Teles De Menezes v. Rubio, 156 F.4th 1

First Circuit, September 18, 2025. After Muñoz, consular nonreviewability is a merits defense rather than a jurisdictional bar, and it does not reach a challenge to the State Department's reclassification of an approved petition as opposed to a visa refusal.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
Towns of Wellesley, Concord & Norwood v. FERC, 829 F.2d 275

First Circuit, September 25, 1987. The First Circuit applies the TRAC factors when asked to compel agency action that has been unreasonably delayed.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 5 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
Patel v. Jaddou, 118 F.4th 475

First Circuit, October 16, 2024. Assuming statutory jurisdiction, § 1255(a) does not forbid USCIS from holding adjustment applications until a visa number is immediately available, so no § 706(1) claim lies against the abeyance policy; the Fourth Circuit rejects deciding the merits before the § 1252(a)(2)(B) question.

ImmCite: caution, adverse or limiting treatment found. Reasoning rejected in the Fourth Circuit by Lolakshi Kale v. Angelica Alfonso-Royals, 139 F.4th 329 (2025).